This data protection declaration is intended to provide you with transparent information about the processing of personal data at Swiss Life Immopulse.
1. Introduction
Swiss Life Immopulse is a business area of Swiss Life Ltd that provides services related to real estate and processes your personal data when you use these services.
Swiss Life Ltd (hereinafter "Swiss Life" or "we") takes the protection of your privacy and personal data extremely seriously. The relevant principles of data protection legislation and other regulatory requirements accordingly apply in everyday practice at Swiss Life.
This includes ensuring that Swiss Life adequately and consistently protects your personal data and safeguards the confidentiality, integrity, availability, traceability and proportionality requirements when processing your data.
Please find below an overview of the processing carried out on personal data by Swiss Life Immopulse. This description is not exhaustive. Other matters relevant to data protection are also dealt with in other specific data protection declarations or general contract and business conditions, conditions of participation and similar documents.
Further information on data protection in relation to individual products or business activities, as well as the processing of your data on our website, can be found at https://www.swisslife.ch/privacy.
2. Controller and data protection officer
In accordance with data protection law, the following company is responsible for the data processing described here:
Swiss Life Ltd
General-Guisan-Quai 40
P.O. Box, 8022 Zurich
For data protection concerns, you can contact us at the following address
Swiss Life Ltd
Data protection consultant
General-Guisan-Quai 40
P.O. Box, 8022 Zurich
E-mail: datenschutz@swisslife.ch
3. Categories of personal data processed
In connection with the services provided by Swiss Life Immopulse, we process, in particular, the following categories of personal data for the purposes set out in no. 4:
- Master data (e.g. first and last names, street, number, place of residence, country of domicile, gender, date of birth, age, marital status, tax domicile, languages, nationalities, country of birth, e-mail address, residence permit, telephone number and other data relating directly to you);
- Property data (e.g. type, location, size, price and possible use);
- Payment data (e.g. payment method data, date and sum of incoming payments, outstanding and paid invoices, reminders);
- Contract data (e.g. data from offers, information on contract conclusions and contracts and their fulfilment, enforcement and termination and other contract-related information);
- Data to fulfil our legal obligations and associated clarifications and reporting;
- Behavioural and preference data (information about specific actions, e.g. payments, the use of electronic communications, interaction with social media profiles, contacts with distribution partners etc.; information about your needs and interests, which we obtain from analysis of existing data but also data from third parties);
- Communication data (e.g. type, time and place of communication and its content).
We usually receive this data from you, but also potentially from third-party sources such as your family members, address service providers (master data), address providers, cooperation partners, credit reporting agencies and other information service providers (e.g. master and financial data), representatives of you and other persons associated with you (e.g. contract data), offices (e.g. information we use for preferential data) and other sources (e.g. the media or Internet).
If you act on behalf of third parties or provide us with data of third parties, we assume that you have informed these third parties about our processing of their personal data. If these persons object to our data processing, this may have an impact on the contract concluded with you.
4. Processing purpose
Swiss Life processes your personal data (no. 3) in connection with real estate services, in particular for the following purposes:
- Fulfilment of statutory and other legal requirements (e.g. from self-regulation, industry standards, official instructions and internal stipulations, e.g. on the prevention of money laundering and the financing of terrorism, clarification of legal and reputation risks, reporting, fulfilment of duties of disclosure, information provision and reporting, archiving, handling complaints and other notifications, monitoring of communication, internal or external investigations, disclosure of documents to the authorities, support in the prevention, detection and investigation of criminal offences and other breaches). We process in particular master data, contract, property and payment data, communication data and, in some cases, behavioural data for these purposes;
- Initiation, conclusion, administration and fulfilment of contracts for the brokerage of real estate or for the analysis and valuation of real estate (in particular property intake and valuation, documentation, negotiation and conclusion, advice, communication, risk assessment, planning, scheduling and client advising, contract management and customer data management, enforcement of contracts (collection, court proceedings etc.), bookkeeping and communication etc.). Processing and administering offers and contracts, including forwarding data to our cooperation partners. For this purpose, we mainly process master data, contract data, financial data and communication data.
- Processing inquiries from real estate portals, maintaining search profiles and processing purchase offers (documenting search queries and search profiles, communication, financing review, scheduling and client advising). Processing and management of inquiries about real estate, from search profiles and purchase offers, including the forwarding of data to our cooperation partners. For this purpose we process, in particular, master data, property data, payment data and communication data.
- Prevention, risk management, legal protection (e.g. risk assessments, prevention of misuse, internal and external investigations, legal proceedings, corporate management and development). For this purpose we process, in particular, master data, contract data and financial data, as well as behavioural and communication data.
- Market research and product development (e.g. analysing the use of our offers, evaluating and improving existing offers and developing new offers). For this purpose we process, in particular, your master data, but also communication data and information from customer surveys, other surveys and studies and other information, e.g. from media monitoring services, from the media, from social media, from the Internet and from other public sources.
- Marketing (e.g. transmission of information and advertising from us and third parties, e.g. as a newsletter or printed matter, targeted addressing of existing customers, holding customer events and competitions, personalisation of information and advertising). To that end, we link data that we process about you and determine preferential data. You may object to the processing for marketing purposes at any time by notifying us. Further information on your rights can be found in no. 8.
- Additional purposes: e.g. security purposes, monitoring buildings and publicly accessible premises, internal administration, training and education, bookkeeping, data archiving, managing IT, safeguarding our rights, evaluating and improving internal processes, statistics and research, safeguarding other legitimate interests.
- Customer service: As part of our customer service, one of our service units may contact you. Swiss Life processes your personal data within the scope of our service units to make appointments for advisory meetings and manage existing customer relationships.
"Processing" means any handling of personal data, e.g. its collection, storage, use, disclosure and deletion, as well as automated evaluation and the determination of preferential data, for risk assessment purposes or to conduct statistical evaluations. This also includes profiling, i.e. automated processing for analysis and forecasting purposes (e.g. to combat money laundering and the financing of terrorism, to combat abuse, for customer care and for marketing purposes.
5. Data recipients
We may disclose data pursuant to no. 3 in particular to the following categories of recipient to the extent required for the purposes pursuant to no. 4:
• Real estate portals, such as Homegate;
• Counterparties and banks in transactions;
• Our Group companies (for details see www.swisslife.com/en/home/about-us.html);
• Real estate brokers, address providers and brokers;
• Authorities, courts and offices;
• Other third parties, e.g. banks or cooperation partners;
• Internal and external service providers (e.g. IT service providers, address and shipping service providers, marketing, distribution, communication or printing service providers, service providers in building management, credit reporting agencies, debt collection service providers, consulting firms, auditors, etc.).
These recipients may be located abroad (e.g. when transmitting personal data to banks and other bodies in connection with assets located abroad, when purchasing IT services, in legal proceedings abroad, etc.). Your data may therefore be processed anywhere in the world, including outside the EU or the European Economic Area (e.g. in the US). Not all of these countries have a level of data protection equivalent to Swiss law. We therefore take contractual precautions and generally make use of standard contractual clauses (further information can be found at https://www.edoeb.admin.ch/edoeb/en/home/datenschutz/arbeit_wirtschaft/datenuebermittlung_ausland.html), unless an exception applies (e.g. in legal proceedings abroad, in cases of overriding public interest if the processing of a contract requires such disclosure, if you have given your consent).
6. Duration of processing
We process your data for as long as our processing purposes, the statutory retention periods and our legitimate interests in processing for documentation and evidence purposes require or storage is technically necessary. The storage duration is based on legal and internal regulations and the processing purposes (no. 4). If these purposes have been achieved or no longer apply and there is no longer any obligation to retain it, we will delete or anonymise your data as part of our usual procedures.
7. Your rights
You have certain rights as defined by the relevant legal conditions and framework:
- to request information from us as to whether and which data we process about you;
- that we correct data if it is inaccurate;
- to object to our processing and to request the deletion of data if we are not obliged or entitled to further processing;
- to ask us to hand over certain personal data in a conventional electronic format or transfer the data to another controller;
- to revoke your consent if our processing is based on your consent.
If we notify you of an automated decision in a specific instance, you have the right to state your position and to request that the decision be reviewed by a natural person.
If you wish to exercise any rights against us, please contact us in writing (no. 2). In order to rule out misuse, we need to identify you.
If you do not agree with our handling of your rights or data protection, please let us know as specified under no. 2. You can contact the Swiss supervisory authority at https://www.edoeb.admin.ch/edoeb/en/home/adresse.html.
8. Restriction of the range of products and services
Swiss Life Switzerland acts exclusively for clients whose head office or domicile is in Switzerland. No marketing or sales activities take place abroad.
Should you be interested in our products as a person domiciled outside Switzerland, we recommend you contact a representative of the Swiss Life Group near you or one of our Group companies via their website (https://www.swisslife.com).
9. Updating our data privacy policy
Swiss Life reserves the right to modify this data protection declaration without prior notice to take account of current statutory provisions and changed business procedures. We will actively inform persons whose contact details are registered with us about major changes as and when they occur, provided this is possible without disproportionate effort. As a general rule, the data protection declaration in its current version at the start of processing applies for data processing. This data protection declaration does not form part of the contract.
Last update: August 2023